OUR CODE OF ETHICS Our Code of Ethics | Page 5

These prohibitions are applicable wherever the Group operates, regardless of the provisions of local legislation. Notwithstanding the above, gifts and hospitality are considered acceptable when they meet the following requirements: They are not in breach of the legislation appli- cable in each country. They are not contrary to the Group’s ethical and transparency-related values. They are given or received as part of what is a generally accepted act of social courtesy or business practice and consist of objects or services generally considered to be of symbolic or economically irrelevant value. If any act of corruption or bribery comes to your attention, report it. Competitors The Lantero Group competes fairly and complies with all the competition laws applicable around the world. Employees who gather, share and use information on our competitors must only do so legally and ethically. Always compete with integrity and comply with applicable antitrust and competition laws. When dealing with our competitors, you must never enter into formal or informal, written or verbal agreements to set prices or conditions of sale, coordinate bids or assign customers, sales territo- ries or product lines, or take part in any other activity in breach of applicable antitrust and competition laws. Breaches of antitrust and competition laws may lead to serious legal sanctions for the company and criminal charges being filed against the individuals involved. 8 Conflicts of Interest You must always avoid anything which may lead to conflict between your personal interests (or those of any member of your family) and the interests of the company when carrying out an activity. Conflicts of interest may arise when either you or a member of your family receives any form of personal or economic benefit from (or has a financial interest in) or works for a supplier, custo- mer, competitor or company seeking to do business with the Group. If at any point in your work, you think you may have a real or potential conflict of interest, you must inform the company immediately. something of value (such as achieving a performan- ce target or receiving payment) or avoid negative consequences (such as disciplinary measures). Confidential information You must protect and not disclose confidential competition-sensitive or proprietary information about the Lantero Group, its customers, suppliers or commercial partners, or third parties. Disciplinary measures If you fail to comply with its Unified Code, the company may take the applicable disciplinary measures according to the misconduct and sanc- tion system in force at the time. The senior manage- ment of the Lantero Group will ensure that this Unified Code is complied with and its own conduct should set an example for all the Group’s employees. the civil and criminal laws in force in the different countries in which the Group operates. You must assume that all company information is confidential or competition sensitive unless there are clear indications that the Lantero Group has made it public. Remember that having a conflict of interest is not necessarily a breach of the Unified Code, but failing to report one is. Company resources You must protect the Lantero Group’s resources. The Group expects you to use the company’s resources honestly and effectively. The company’s resources include physical assets, such as its facilities, supplies, equipment, machi- nery, spare parts, raw materials, finished products, vehicles and funds. They also include intangible assets, such as confidential information, intellectual property and information systems. You must use the company’s resources only for legitimate commercial purposes and protect them against theft, loss, damage and improper use. Your obligation to protect the company’s funds is particularly important if you are authorized to spend money, approve expenses or manage budgets. Fraud Fraud consists of using the company’s resources in an improper manner when you intentionally conceal, alter, falsify or omit information for your own personal benefit or for that of others. Fraud may be motivated by the opportunity to obtain 9